Composite products containing ingredients from animal origins to require new Export Health Certificate

A new model Export Health Certificate (EHC) will come into force on 21 April 2021, which will impact the export of composite products containing products of animal origin (POAO) as an ingredient, such as lasagne, pork pies, and pepperoni pizza.

Under the new regulation, EHC requirements will be extended to include dairy products and other ingredients in composite food products – i.e. food items which contain a mix of processed POAO such as meat and dairy – and plant products used as a main ingredient. –  which were previously not required to be listed.

What does this mean?

Browwyn Magee, trainee analyst at AHDB, reported that under these new requirements, all POAO within a composite product will require an EHC, where previously just the composite product needed an EHC.

“For example, a shipment of lasagne would require an EHC, and under the new regulation, so will the cheese, milk and beef content within it,” Ms Magee explained. “This means several new EHCs will need to be issued, compounding the added cost of exporting.

At present, composite food products exported to the EU from GB are required to be checked at a Border Control Point (BPC), unless the product is exempt. However, not all BCPs accept all goods, and so businesses will be required to use a BCP that is able to check all their products, which could redirect some trade, as goods may be refused entry if an incorrect BPS is used.

Composite products that are exempt from EHC requirements include products that meet certain conditions, such as a biscuit as it is a shelf stable product and its dairy content is below the defined threshold.

Ms Magee added: “Ultimately, these changes will add further friction to UK-EU trade, as they increase both the administration burden and add cost to UK businesses.”

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